EX-1.01 2 exhibit101conflictminerals.htm EXHIBIT 1.01 Exhibit
Exhibit 1.01

Malibu Boats, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2018


Introduction    
    
This Conflict Minerals Report (“CMR”) for the year ended December 31, 2018 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule imposes certain reporting obligations on U.S. Securities and Exchange Commission (“SEC”) issuers if they manufacture or contract to manufacture products that contain certain minerals which are necessary to the functionality or production of their products. These minerals are cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten (“3TG” or “Conflict Minerals”). The Rule focuses on 3TG emanating from the Democratic Republic of Congo (“DRC”) region and nine adjoining countries (together, the “Covered Countries”). If an issuer has reason to believe that any of the Conflict Minerals in their supply chain may have originated in the Covered Countries and are not from recycled or scrap sources, or if they are unable to determine the country of origin of those Conflict Minerals, then the issuer must exercise due diligence on the Conflict Minerals’ source and chain of custody and file a CMR as an exhibit to the Form SD with the SEC that includes a description of those due diligence measures.

Company Overview

Malibu Boats, Inc., also referred to as “Malibu Boats”, “we”, “our”, and “us” is a leading designer, manufacturer and marketer of a diverse range of recreational powerboats, including performance sport boats, sterndrive and outboard boats. Our boats are used for water sports, general recreational boating and fishing. Our high performance boats are sold under four brands: Malibu; Axis; Cobalt and Pursuit. We manufacture our own Malibu, Axis, Cobalt and Pursuit performance boats and components such as trailers, towers and tower accessories. In addition, we contract with other third-party vendors to manufacture other components for installation on our boats, such as engines and electronic controls and pursuant to our engine integration strategy, beginning with our model year 2019 boats we are purchasing engines from General Motors LLC and preparing them for marine use. We determined that Conflict Minerals were necessary to the functionality and/or production of such products during calendar year 2018.

Executive Summary

Malibu Boats does not directly source any Conflict Minerals that may be used in the products we manufacture or contract to manufacture. Therefore we relied upon our suppliers to provide information on the origin of the Conflict Minerals contained in components and materials supplied to us, including sources of Conflict Minerals that are supplied to them from sub-tier suppliers. Malibu Boats performed a Reasonable Country of Origin Inquiry (“RCOI”) on suppliers believed to provide Malibu Boats with materials or components containing necessary 3TGs.

Malibu Boats’ suppliers identified 318 valid smelters and refineries (“smelters”). Of these 318 smelters, Malibu Boats identified 47 as sourcing (or there was a reason to believe they may be sourcing) from the Covered Countries. Malibu Boats’ due diligence review indicated that 38 of these smelters have been audited and recognized as conflict free by the Responsible Minerals Assurance Process (“RMAP,” previously known as the Conflict Free Smelter Program or CFSP) and designated as RMAP Conformant by the Responsible Minerals Initiative (previously known as the Conflict Free Sourcing Initiative). The remaining nine smelters sourcing from the Covered Countries were subjected to Malibu Boats’ risk mitigation process in accordance with the Organisation for Economic Co-Operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas (“OECD Due Diligence Guidance”), as described below.

Although we requested information at a product level, many suppliers returned information at a company or division level, not at a product level. Such suppliers were unable to specify the smelters used for components supplied to Malibu Boats. Therefore the information provided was not necessarily limited to smelters contained in components supplied to us and confirmed to be in the Company’s supply chain.

Company Management Systems

Malibu Boats established strong management systems according to Step 1 of the OECD Due Diligence Guidance. Malibu Boats implemented the following:

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Exhibit 1.01


Step 1A - Adopted, and clearly communicated to suppliers and the public, a company policy for the supply chain of minerals originating from conflict-affected and high-risk areas. Malibu Boats:
implemented a conflict minerals policy, which is publicly available at https://investors.malibuboats.com/corporate-governance/governance-documents/; and
communicated the policy directly to suppliers as part of the RCOI process.
Step 1B - Structured internal management to support supply chain due diligence. Malibu Boats:
maintained an internal cross functional team to support supply chain due diligence;
appointed a member of the senior staff with the necessary competence, knowledge, and experience to oversee supply chain due diligence; and
applied the resources necessary to support the operation and monitoring of these processes including internal resources and external consulting support.
Step 1C - Established a system of transparency, information collection and control over the supply chain. Malibu Boats:
implemented a process to collect required supplier and smelter RCOI and due diligence data.
Step 1D - Strengthened company engagement with suppliers. Malibu Boats:
engaged directly with suppliers during the RCOI process;
reviewed supplier responses as part of the RCOI process;
added conflict minerals compliance to new supplier contracts and Malibu Boats’ supplier code of conduct; and
implemented a plan to improve the quantity and quality of supplier and smelter responses year over year.
Step 1E - Established a company and/or mine level grievance mechanism. Malibu Boats:
recognized the RMAP’s three audit protocols for gold, tin/tantalum, and tungsten as valid sources of smelter or mine level grievances; and
reviewed Malibu Boats’ ethics violations reporting system to ensure that it allows employees to voice confidentially without any fear of retribution, any concerns with the violations of the Malibu Boats’ conflict minerals policy.

Reasonable Country of Origin Inquiry

Malibu Boats designed its RCOI process in accordance with Steps 2A and 2B of the OECD Due Diligence Guidance. Malibu Boats’ RCOI process involved two stages:

Stage 1 - Supplier RCOI (Step 2A of the OECD Due Diligence Guidance)
Stage 2 - Smelter RCOI (Step 2B of the OECD Due Diligence Guidance)

Supplier RCOI

Malibu Boats designed its supplier RCOI process to identify, to the best of Malibu Boats’ efforts, the smelters in Malibu Boats’ supply chain in accordance with Step 2A of the OECD Due Diligence Guidance. Malibu Boats’ supplier RCOI process for the 2018 reporting period included the following:

developed a list of suppliers providing components containing 3TG to Malibu Boats;
contacted each supplier and requested the industry standard Conflict Minerals Reporting Template including smelter information;
reviewed supplier responses for accuracy and completeness;
amalgamated supplier provided smelters into a single list of smelters meeting the definition of a smelter under one of three industry recognized audit protocols; and
reviewed the final smelter list (and compared it to industry peers) to determine if Malibu Boats identified reasonably all of the smelters in their supply chain.

Malibu Boats’ suppliers identified 318 smelters in their supply chain. The specific list of smelters is included in “List of Smelter and Refineries” at the end of this report.

Smelter RCOI

Due to the overlap between smelter RCOI and smelter due diligence, the smelter RCOI process is summarized in the due diligence section of this report.


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Exhibit 1.01

Due Diligence

Malibu Boats’ due diligence process was designed in accordance with the applicable sections of Steps 2, 3, and 4 of the OECD Due Diligence Guidance.

Smelter RCOI and Due Diligence

Malibu Boats’ smelter RCOI and due diligence process were designed to:

identify the scope of the risk assessment of the mineral supply chain (OECD Due Diligence Guide Step 2B);
assess whether the smelters have carried out all elements of due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas (OECD Due Diligence Guide Step 2C); and
carry out, where necessary, including through participation in industry-driven programs, joint spot checks at the mineral smelter’s own facilities (OECD Due Diligence Guide Step 2D).

Malibu Boats’ smelter RCOI and due diligence process included the following:

For each smelter identified in Malibu Boats’ supply chain, Malibu Boats:
attempted to engage directly with the smelter to determine whether or not the smelter sources from the Covered Countries;
reviewed publicly available information to determine if there was any contrary evidence to the smelter’s declaration for smelters that declared directly or through their relevant industry association that they did not source from the Covered Countries, and were not recognized as conflict free by the RMAP; and
reviewed publicly available sources to determine if there was any reason to believe that the smelter may have sourced from the Covered Countries during the reporting period for smelters that did not respond to our direct engagement.

For high risk smelters (smelters that are sourcing from or there is reason to believe they may be sourcing from the Covered Countries), Malibu Boats determined if the smelter was audited and recognized as conflict free by the RMAP.
For high risk smelters that have not been audited and recognized as conflict free by the RMAP, Malibu Boats communicated the risk to a designated member of senior management (OECD Due Diligence Guide Step 3A) and conducted risk mitigation on the smelter according to OECD Due Diligence Guide Step 3B.

For the 2018 reporting period, Malibu Boats’ RCOI and due diligence process was executed by Claigan Environmental Inc.

Malibu Boats’ suppliers identified 318 smelters. Malibu Boats identified 47 smelters that source, or there is a reason to believe they source, from the Covered Countries.

Malibu Boats determined that 38 of these 47 smelters have been audited and recognized as conflict free by the RMAP or RMAP Conformant. Malibu Boats conducted risk mitigation on the remaining nine smelters as discussed below.

Risk Mitigation

Malibu Boats conducted risk mitigation on nine smelters that were not recognized as conflict free by the RMAP and were sourcing from the Covered Countries. Malibu Boats’ risk mitigation was designed in accordance with Step 3B of the OECD Due Diligence Guidance and was reported to our Chief Financial Officer in accordance with Step 3A of the OECD Due Diligence Guidance. Malibu Boats’ risk mitigation process included the following:

conducted additional due diligence to determine if there was any reason to believe the smelter directly or indirectly financed or benefited armed groups in the Covered Countries;
attempted to verify with internal stakeholders and relevant suppliers whether 3TGs from the specific smelter were actually in Malibu Boats’ supply chain in the 2018 reporting period; and
engaged directly with each high risk smelter to verify risk and to encourage the smelter to become conflict free.

As discussed above, as many suppliers return information at a company or division level, and not at a product level, we are not able to determine if the nine remaining smelters are confirmed to be in Malibu Boats’ supply chain. We will continue to work with our suppliers to determine if these nine smelters can be directly linked to the actual parts or products sold to Malibu Boats.

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Exhibit 1.01


In addition, as part of our risk mitigation process we have engaged with each of them to verify risk and to encourage the smelter to become conflict free. We are continuing to work with the suppliers who currently have these nine smelters in their supply chain to evaluate the removal of these smelters from their supply chain.

Improvement Plan

Malibu Boats is taking and will continue to take the following steps to improve the due diligence conducted to further mitigate any risk that the Conflict Minerals contained in the products manufactured or contracted for manufacture by Malibu Boats could directly or indirectly benefit or finance armed groups in the Covered Countries:

including a conflict minerals clause in all new and renewing supplier contracts;
continuing to drive our suppliers to obtain current, accurate, and complete information about the smelters in their supply chain;
continuing to work with our suppliers to encourage the removal of any high risk smelters;
evaluating ongoing supplier relationships with those suppliers that do not comply with our conflict minerals policy;
engaging smelters sourcing from the Covered Countries to become audited and certified to a protocol recognized by the RMAP; and
following up in 2019 on the smelter requiring risk mitigation, but not removal from Malibu Boats’ supply chain.

List of Smelters and Refineries

Below are the smelters reported to Malibu Boats as likely to be in Malibu Boats’ supply chain in the 2018 reporting period. 47 of the smelters below are declared to be sourcing or there was reason to believe they may be sourcing from the Covered Countries. Under the SEC Final Rule, the requirement is to identify whether or not a smelter is sourcing from the Covered Countries; there is no requirement to identify the specific covered country by smelter. Given the limitation on the specificity of the smelters’ disclosures, the identified Covered Countries are The Democratic Republic of the Congo, Rwanda, Burundi, and Tanzania. As noted above, Malibu Boats has determined that of these 47 smelters, 38 have been audited and recognized as conflict free by the RMAP and Malibu Boats conducted risk mitigation on the remaining nine smelters.

Metal        Smelter Name
Gold
8853 S.p.A.
Gold
Abington Reldan Metals, LLC
Gold
Advanced Chemical Company
Gold
African Gold Refinery
Gold
Aida Chemical Industries Co., Ltd.
Gold
Al Etihad Gold Refinery DMCC
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
Gold
AngloGold Ashanti Córrego do Sítio Mineração
Gold
Argor-Heraeus S.A.
Gold
Asahi Pretec Corp.
Gold
Asahi Refining Canada Ltd.
Gold
Asahi Refining USA Inc.
Gold
Asaka Riken Co., Ltd.
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
Gold
AU Traders and Refiners
Gold
Aurubis AG
Gold
Bangalore Refinery
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Gold
Boliden AB
Gold
C. Hafner GmbH + Co. KG
Gold
Caridad

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Exhibit 1.01

Gold
CCR Refinery - Glencore Canada Corporation
Gold
Cendres + Métaux S.A.
Gold
Chimet S.p.A.
Gold
Chugai Mining
Gold
Daejin Indus Co., Ltd.
Gold
Daye Non-Ferrous Metals Mining Ltd.
Gold
Degussa Sonne / Mond Goldhandel GmbH
Gold
Dijllah Gold Refinery FZC
Gold
DODUCO Contacts and Refining GmbH
Gold
Dowa
Gold
DS PRETECH Co., Ltd.
Gold
DSC (Do Sung Corporation)
Gold
Eco-System Recycling Co., Ltd.
Gold
Emirates Gold DMCC
Gold
Fidelity Printers and Refiners Ltd.
Gold
Fujairah Gold FZC
Gold
Geib Refining Corporation
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
Gold
Guangdong Jinding Gold Limited
Gold
Gujarat Gold Centre
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
Gold
HeeSung Metal Ltd.
Gold
Heimerle + Meule GmbH
Gold
Henan Yuguang Gold & Lead Co., Ltd.
Gold
Heraeus Metals Hong Kong Ltd.
Gold
Heraeus Precious Metals GmbH & Co. KG
Gold
Hunan Chenzhou Mining Co., Ltd.
Gold
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
Gold
HwaSeong CJ Co., Ltd.
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
Gold
International Precious Metal Refiners
Gold
Ishifuku Metal Industry Co., Ltd.
Gold
Istanbul Gold Refinery
Gold
Italpreziosi
Gold
Japan Mint
Gold
Jiangxi Copper Co., Ltd.
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
Gold
JSC Uralelectromed
Gold
JX Nippon Mining & Metals Co., Ltd.
Gold
Kaloti Precious Metals
Gold
Kazakhmys Smelting LLC
Gold
Kazzinc
Gold
Kennecott Utah Copper LLC
Gold
KGHM Polska Miedź Spółka Akcyjna
Gold
Kojima Chemicals Co., Ltd.
Gold
Korea Zinc Co., Ltd.
Gold
Kyrgyzaltyn JSC
Gold
Kyshtym Copper-Electrolytic Plant ZAO

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Exhibit 1.01

Gold
L'azurde Company For Jewelry
Gold
Lingbao Gold Co., Ltd.
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
Gold
L'Orfebre S.A.
Gold
LS-NIKKO Copper Inc.
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
Gold
Marsam Metals
Gold
Materion
Gold
Matsuda Sangyo Co., Ltd.
Gold
Metalor Technologies (Hong Kong) Ltd.
Gold
Metalor Technologies (Singapore) Pte., Ltd.
Gold
Metalor Technologies (Suzhou) Ltd.
Gold
Metalor Technologies S.A.
Gold
Metalor USA Refining Corporation
Gold
Metalúrgica Met-Mex Peñoles S.A. De C.V.
Gold
Mitsubishi Materials Corporation
Gold
Mitsui Mining and Smelting Co., Ltd.
Gold
MMTC-PAMP India Pvt., Ltd.
Gold
Modeltech Sdn Bhd
Gold
Morris and Watson
Gold
Moscow Special Alloys Processing Plant
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.
Gold
Navoi Mining and Metallurgical Combinat
Gold
NH Recytech Company
Gold
Nihon Material Co., Ltd.
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
Gold
Ohura Precious Metal Industry Co., Ltd.
Gold
OJSC "The Gulidov Krasnoyarsk Non- Ferrous Metals Plant" (OJSC Krastsvetmet)
Gold
OJSC Novosibirsk Refinery
Gold
PAMP S.A.
Gold
Pease & Curren
Gold
Penglai Penggang Gold Industry Co., Ltd.
Gold
Planta Recuperadora de Metales SpA
Gold
Prioksky Plant of Non-Ferrous Metals
Gold
PT Aneka Tambang (Persero) Tbk
Gold
PX Précinox S.A.
Gold
QG Refining, LLC
Gold
Rand Refinery (Pty) Ltd.
Gold
Refinery of Seemine Gold Co., Ltd.
Gold
Remondis Argentia B.V.
Gold
Republic Metals Corporation
Gold
Royal Canadian Mint
Gold
SAAMP
Gold
Sabin Metal Corp.
Gold
Safimet S.p.A
Gold
SAFINA A.S.
Gold
Sai Refinery
Gold
Samduck Precious Metals
Gold
SAMWON Metals Corp.
Gold
SAXONIA Edelmetalle GmbH

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Exhibit 1.01

Gold
SEMPSA Joyería Platería S.A.
Gold
Shandong Humon Smelting Co., Ltd.
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
Gold
Shenzhen Zhonghenglong Real Industry Co., Ltd.
Gold
Sichuan Tianze Precious Metals Co., Ltd.
Gold
Singway Technology Co., Ltd.
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
Gold
Solar Applied Materials Technology Corp.
Gold
State Research Institute Center for Physical Sciences and Technology
Gold
Sudan Gold Refinery
Gold
Sumitomo Metal Mining Co., Ltd.
Gold
SungEel HiMetal Co., Ltd.
Gold
Super Dragon Technology Co., Ltd.
Gold
T.C.A S.p.A
Gold
Tanaka Kikinzoku Kogyo K.K.
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
Gold
Tokuriki Honten Co., Ltd.
Gold
Tongling Nonferrous Metals Group Co., Ltd.
Gold
Tony Goetz NV
Gold
TOO Tau-Ken-Altyn
Gold
Torecom
Gold
Umicore Brasil Ltda.
Gold
Umicore Precious Metals Thailand
Gold
Umicore S.A. Business Unit Precious Metals Refining
Gold
United Precious Metal Refining, Inc.
Gold
Universal Precious Metals Refining Zambia
Gold
Valcambi S.A.
Gold
Western Australian Mint (T/a The Perth Mint)
Gold
WIELAND Edelmetalle GmbH
Gold
Yamakin Co., Ltd.
Gold
Yokohama Metal Co., Ltd.
Gold
Yunnan Copper Industry Co., Ltd.
Gold
Zhongkuang Gold Industry Co., Ltd.
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
Tantalum
Asaka Riken Co., Ltd.
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
Tantalum
D Block Metals, LLC
Tantalum
Exotech Inc.
Tantalum
F&X Electro-Materials Ltd.
Tantalum
FIR Metals & Resource Ltd.
Tantalum
Global Advanced Metals Aizu
Tantalum
Global Advanced Metals Boyertown
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
Tantalum
H.C. Starck Co., Ltd.
Tantalum
H.C. Starck Hermsdorf GmbH
Tantalum
H.C. Starck Inc.
Tantalum
H.C. Starck Ltd.
Tantalum
H.C. Starck Smelting GmbH & Co. KG

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Exhibit 1.01

Tantalum
H.C. Starck Tantalum and Niobium GmbH
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
Tantalum
Jiangxi Tuohong New Raw Material
Tantalum
Jiujiang Janny New Material Co., Ltd.
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
Tantalum
Jiujiang Tanbre Co., Ltd.
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
Tantalum
KEMET Blue Metals
Tantalum
KEMET Blue Powder
Tantalum
LSM Brasil S.A.
Tantalum
Metallurgical Products India Pvt., Ltd.
Tantalum
Mineração Taboca S.A.
Tantalum
Mitsui Mining & Smelting
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
Tantalum
NPM Silmet AS
Tantalum
Power Resources Ltd.
Tantalum
QuantumClean
Tantalum
Resind Indústria e Comércio Ltda.
Tantalum
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.
Tantalum
Solikamsk Magnesium Works OAO
Tantalum
Taki Chemicals
Tantalum
Telex Metals
Tantalum
Ulba Metallurgical Plant JSC
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
Tin
Alpha
Tin
An Vinh Joint Stock Mineral Processing Company
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
Tin
China Tin Group Co., Ltd.
Tin
CV Ayi Jaya
Tin
CV Dua Sekawan
Tin
CV Gita Pesona
Tin
CV United Smelting
Tin
CV Venus Inti Perkasa
Tin
Dowa
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
Tin
EM Vinto
Tin
Estanho de Rondônia S.A.
Tin
Fenix Metals
Tin
Gejiu Fengming Metallurgy Chemical Plant
Tin
Gejiu Kai Meng Industry and Trade LLC
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
Tin
HuiChang Hill Tin Industry Co., Ltd.
Tin
Huichang Jinshunda Tin Co., Ltd.
Tin
Jiangxi New Nanshan Technology Ltd.

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Exhibit 1.01

Tin
Magnu's Minerais Metais e Ligas Ltda.
Tin
Malaysia Smelting Corporation (MSC)
Tin
Melt Metais e Ligas S.A.
Tin
Metallic Resources, Inc.
Tin
Metallo Belgium N.V.
Tin
Metallo Spain S.L.U.
Tin
Mineração Taboca S.A.
Tin
Minsur
Tin
Mitsubishi Materials Corporation
Tin
Modeltech Sdn Bhd
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
Tin
O.M. Manufacturing Philippines, Inc.
Tin
Operaciones Metalurgical S.A.
Tin
Pongpipat Company Limited
Tin
PT Aries Kencana Sejahtera
Tin
PT Artha Cipta Langgeng
Tin
PT ATD Makmur Mandiri Jaya
Tin
PT Babel Inti Perkasa
Tin
PT Bangka Prima Tin
Tin
PT Bangka Serumpun
Tin
PT Bangka Tin Industry
Tin
PT Belitung Industri Sejahtera
Tin
PT Bukit Timah
Tin
PT DS Jaya Abadi
Tin
PT Inti Stania Prima
Tin
PT Karimun Mining
Tin
PT Kijang Jaya Mandiri
Tin
PT Lautan Harmonis Sejahtera
Tin
PT Menara Cipta Mulia
Tin
PT Mitra Stania Prima
Tin
PT Panca Mega Persada
Tin
PT Premium Tin Indonesia
Tin
PT Prima Timah Utama
Tin
PT Rajehan Ariq
Tin
PT Refined Bangka Tin
Tin
PT Sariwiguna Binasentosa
Tin
PT Stanindo Inti Perkasa
Tin
PT Sukses Inti Makmur
Tin
PT Sumber Jaya Indah
Tin
PT Timah (Persero) Tbk Kundur
Tin
PT Timah (Persero) Tbk Mentok
Tin
PT Tinindo Inter Nusa
Tin
PT Tommy Utama
Tin
Resind Indústria e Comércio Ltda.
Tin
Rui Da Hung
Tin
Soft Metais Ltda.
Tin
Super Ligas
Tin
Thaisarco
Tin
Tin Technology & Refining

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Exhibit 1.01

Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
Tin
White Solder Metalurgia e Mineração Ltda.
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
Tin
Yunnan Tin Company Limited
Tungsten
A.L.M.T. TUNGSTEN Corp.
Tungsten
ACL Metais Eireli
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
Tungsten
Global Tungsten & Powders Corp.
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
Tungsten
H.C. Starck Smelting GmbH & Co. KG
Tungsten
H.C. Starck Tungsten GmbH
Tungsten
Hunan Chenzhou Mining Co., Ltd.
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
Tungsten
Hydrometallurg, JSC
Tungsten
Japan New Metals Co., Ltd.
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
Tungsten
Kennametal Fallon
Tungsten
Kennametal Huntsville
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
Tungsten
Moliren Ltd.
Tungsten
Niagara Refining LLC
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
Tungsten
Philippine Chuangxin Industrial Co., Inc.
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
Tungsten
Unecha Refractory Metals Plant
Tungsten
Wolfram Bergbau und Hütten AG
Tungsten
Woltech Korea Co., Ltd.
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
Tungsten
Xiamen Tungsten Co., Ltd.
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.


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